Ron Lykins, Inc. - Page 1

                                 T.C. Memo. 2006-35                                   


                               UNITED STATES TAX COURT                                


                           RON LYKINS, INC., Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 6795-03.              Filed March 2, 2006.                  


               Ronald G. Lykins, pro se.                                              
               Stephen J. Neubeck, for respondent.                                    


                                 MEMORANDUM OPINION                                   

               HOLMES, Judge:  Ron Lykins, Inc., is a well-established firm           
          in central Ohio that for many years sold both accounting and                
          financial advice to its clients.  In 2000, the sole owner of the            
          company--Ronald Lykins--split off the financial advisory business           
          to a new company.  This left Lykins Inc. selling nothing but                
          accounting services, and the Commissioner argues that this made             





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